Dubai Enacts Strong Whistleblower Protection to Safeguard Public Funds 

Dubai introduces detailed whistleblower protection measures to safeguard public funds, promote transparency and accountability in government operations. 

In a move aimed at enhancing public sector accountability and transparency, Dubai has introduced a legal framework for protecting whistleblowers who report financial or administrative violations within government entities.

In May 2025, Chairman of the Financial Audit Authority (FAA), issued FAA Decision No. (2) of 2025 on Job Protection for Whistleblowers in the Public Service (hereinafter referred to as “Decision No.2”).

Published in the Dubai Official Gazette, Issue No. 719, this Decision recognizes the role of whistleblowers and institutionalizes protection mechanisms for them. 

Scope and applicability of FAA decision 

Decision No.2 covers a wide range of employees working in government and government-linked entities supervised by the FAA. These include government departments, public authorities, councils, and regulators operating in free zones like Dubai International Financial Centre (DIFC) and Special Development Zones. Companies in which the Dubai government owns at least a 25 percent stake and other designated entities are also included. Federal government employees, however, fall outside the scope of this decision, as it specifically targets entities within the Dubai government. 

But the federal government employees fall outside the scope, as the law specifically refers to the Government of Dubai. 

Dubai whistleblower protection mechanisms and reporting process 

The new rules establish a confidential and secure procedure for reporting suspected violations. Employees must submit their reports through an online FAA-managed portal designed to protect the whistleblower’s identity and report details. Whistleblowers must also formally request protection along with their submissions. Once the FAA validates the report, the whistleblower receives formal protection status, and the case is recorded in an official register. 

The law specifically prohibits any retaliation against whistleblowers, such as workplace harassment, demotions, or dismissals. However, protection may be withdrawn if reports are found to be malicious or criminal in nature. 

Streamlined handling of minor offences 

Alongside whistleblower protections, FAA Decision No. (3) of 2025 (hereinafter, “Decision No. 3”) provides clear guidelines for addressing minor administrative offences within public entities. The law identifies which cases can be managed administratively without escalating to public prosecution, particularly those involving no financial loss, malicious intent, or abuse of authority.

Decision No. 3 requires thorough documentation and clear justification when cases are not escalated, while allowing the FAA to revisit these cases if needed. This approach optimizes resources and ensures clarity in managing less serious infractions. 

Institutions for disciplinary and grievance procedures 

In addition, FAA Decision No. (4) of 2025 (hereinafter, Decision No. 4) outlines rules for the Central Violations Committee and the Grievance Committee, providing clear and transparent processes for handling disciplinary issues. This decision establishes clear procedures for: 

• Investigating and adjudicating violations in FAA-regulated entities; 

• Recording meeting minutes, testimony, and evidence; 

• Notifying employees of charges and allowing access to case materials; and 

• Structuring penalties to align with the nature and severity of violations. 

Employees facing accusations must also be clearly informed of charges and given full access to case materials. 

To avoid bias, Grievance Committee members are required to not serve on the Violations Committee and must hold positions equal or senior to the employee filing the grievance. Grievances must be filed within 15 working days of notification, ensuring timely resolution and procedural fairness. 

Implications for public sector integrity 

This legal trio of Decisions (No. 2, 3, and 4) represent Dubai’s efforts to align its governance practices with global standards. Before these laws, whistleblower protections in the UAE were mainly confined to financial free zones or specific federal bodies.

With these new protections, Dubai extends whistleblower safeguards broadly across its governmental operations. The focus on confidentiality and clear anti-retaliation measures aims to encourage early reporting of misconduct, improving internal compliance and financial oversight. 

Read further: EU Removes UAE from High-Risk Money Laundering List 

Challenges and compliance considerations 

Implementation of these rules requires organizations under FAA jurisdiction to quickly update internal policies, reporting procedures, and investigation protocols. Senior management and executives should ensure their organizations meet compliance requirements by providing employee training and clear documentation processes. Entities may also designate personnel to manage violation reports and grievances effectively. Failure to comply may lead to regulatory scrutiny and administrative penalties. 

In short 

Dubai’s new whistleblower protection laws represent a proactive step towards strengthening integrity and accountability within public administration. Through Decisions No. 2, 3, and 4, Dubai has established clear guidelines to encourage responsible reporting, protect employees, and manage internal disciplinary matters efficiently.  

Read more: UAE Investment Procedure, Requirements for Foreign Investors 

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